Canadian domestic law imposes a withholding tax of 25 per cent on income derived by a beneficiary of an estate or trust which is resident in Canada. Article 20(1) provides that, where the income is received and beneficially owned by a resident of the United Kingdom, the withholding tax is reduced to 15 per cent.

If a United Kingdom resident beneficiary has received such income under deduction of Canadian withholding tax at 25 per cent, he can claim repayment of 10 per cent (25 per cent-15 per cent) following the procedure set out in DT4618.

Credit is only available for tax at 15 per cent against the United Kingdom tax on the same income.